Dear e-Stewards Recyclers, Enterprises, and Leadership Council,
We have recently received a number of requests asking BAN to inform you directly if a certified e-Stewards recycler has been officially removed from the list of certified recyclers/refurbishers, i.e. due to their certificate being suspended or completely withdrawn for any reason. Many of you rely on other e-Stewards for your downstream, and therefore, from now on, we will make it a practice to communicate directly with you in these cases.
It is with significant regret that we inform you that Total Reclaim, with locations in Seattle, WA; Portland, OR; and Anchorage, AK has had their e-Stewards certification withdrawn for 2 years, effective May 3, 2016.
The cause of this withdrawal is the discovery, via BAN’s e-Trash Transparency Project, of Total Reclaim’s export of two LCD screens to developing countries in violation of the e-Stewards Standard.
For the past 2 years, with the support of a grant from the Body Shop Foundation, BAN has been engaged in a project to map and understand the flows of actual hazardous e-waste within and exported from the US. This has been accomplished through the use of electronic tracking devices placed into non-functional, economically unrepairable electronic equipment delivered to publicly accessible e-waste recycling drop-off sites around the country. In this particular case, BAN did not deliver directly to Total Reclaim, but 2 tracker-enabled LCD screens passed through Total Reclaim’s facilities.
Unfortunately, these two LCD screens (with mercury-containing CCFL backlights) were shown by the trackers to have been directly exported by Total Reclaim to Hong Kong, which is not only disallowed in the e-Stewards Standard, but is highly likely to be illegal under the laws in the importing country. The evidence was corroborated by onsite visits to Hong Kong of the locations where Total Reclaim’s LCDs were sent.
This information caused BAN to administer its Critical Non-Conformity Policy process, which began by presenting Total Reclaim with the evidence of these exports, in the form of a draft Evidentiary Report, and allowed them to respond to the evidence and to present any corrections, explanations, and extenuating circumstances. Total Reclaim has admitted to their activities in a public statement.
The results of BAN’s larger e-Trash Transparency Project, which uncovered many organizations (of all types) exporting e-waste, will be published in a series of reports. BAN’s first report in this series will likely be published the week of May 9th, 2016. We expect the findings of this report will at the same time be aired on the PBS NewsHour show. We will send out notification of the actual dates once they are final.
While no certification program has 100% compliance by all certified entities, what is of vital importance is how a program verifies its compliance and how it responds to willful violations of this kind. BAN has recently put two additional layers of oversight into the e-Stewards program on top of the scheduled annual audits that accredited certification bodies perform. BAN has instituted the Performance Verification program last year, which performs unannounced inspections on certified e-Stewards recyclers, randomly chosen. In addition, BAN is now using electronic tracking devices placed into hazardous e-waste and monitoring where in the world this hazardous e-waste goes and where it ends up. This latter technology is highly effective in rooting out those that might make an effort to mislead an audit program.
There is no excuse for exporting hazardous e-waste in violation of laws in importing countries. And it is unconscionable to willfully violate a certification you have agreed to uphold. But we also know that the e-recycling industry in the US is struggling to stay alive. It exists in a country that has almost no laws restricting exports (despite laws in the importing countries) and where customers and manufacturers in state takeback programs are all too often not adequately paying for the true environmental services provided by responsible recyclers, now that the value of global commodities has dropped. Recyclers, state programs, customers and all of us really are caught in a broken system that does not provide a national framework of regulations designed and enforced to effectively provide a sustainable and ethical electronics recycling infrastructure to manage North America’s hazardous electronic waste. We hope e-Stewards recyclers will join us at the upcoming Face-to-Face meeting and/or you’ll call or write us so together we can strategize the best path forward for an industry in crisis.
We know this situation is painful, and difficult to explain to your customers and employees. For that reason we have created an FAQ to accompany this note.